
"There is no danger," from the AEC
booklet, "Atomic Tests in Nevada" 1957
Scientific testing has found that elements from nuclear
fallout have traveled 800 feet underground to the proposed repository
horizon during the past 50 years and that groundwater moves off the site
within a few dozen to few hundred years, far faster than the minimum 1,000
year time frame set in current regulations. These problems show that it
would be very difficult, if not impossible, for the site to meet existing
laws, scientific and technical criteria, and human health standards for
groundwater or radiation protection. The “fix” for this dilemma has been to
change or eliminate the regulations to accommodate the deficiencies of the
site.
The nation’s high-level waste repository is supposed to
safely dispose of 77,000 tons of deadly radioactive waste (currently 11
billion curies, compared with the 80 to 100 million curies released from the
Chernobyl nuclear plant that killed thousands of people and contaminated
many parts of Europe). The current design concept for Yucca Mountain is
almost entirely reliant upon manmade, “engineered barriers” (such as the
waste containers) because the mountain itself will not contain the waste.
This design further demonstrates the site’s problems and is contrary to the
fundamental premise of federal law that the site alone provide primary
natural waste isolation.
By the Department of Energy’s own analysis, 150-400
accidents are expected over the 20-30 year period of shipping. In the case
of a serious accident from the projected 50,000 or more shipments, dozens of
people could die immediately, others could be seriously injured, and cleanup
would cost tens of billions of dollars and take months or years to complete.
This does not include the millions to billions of dollars lost to the local
economy from the stigma of being contaminated.
Irradiated fuel from a nuclear power plant is the
deadliest material humans have yet to produce. Even it has cooled for ten
years a person standing a few feet away would get a lethal dose in 3
minutes.
It appears that the Department of Energy is the only
entity familiar with the facts at Yucca Mountain that does not see your
decision as premature. As you know, your own contractor Bechtel/SAIC, as
well as the General Accounting Office, the Nuclear Regulatory Commission,
the Advisory Committee on Nuclear Waste, the Yucca Mountain Technical Review
Board, the National Academy of Sciences, and, recently, the International
Atomic Energy Agency and the OECD’s Nuclear Energy Agency, have each
concluded that significant additional studies need to be performed before
DOE can seriously consider whether to recommend the Yucca Mountain site for
permanent nuclear waste disposal. For example, NRC has indicated that at
least 292 major studies remain to be completed in 19 key areas, including
corrosion of the waste packages, potential effects of volcanic activity,
rapid groundwater flow rates through the mountain, large uncertainties in
predicted repository performance, even the very design of the repository
itself.
In particular, many of the organizations noted above have
commented on DOE’s newly improvised “total system” approach to nuclear waste
storage at Yucca Mountain, an approach that appears designed to ignore the
blatant unsuitability of the geology at Yucca Mountain for the isolation of
radioactive waste. As you know, Nevada has taken legal action against DOE
over this very issue on the grounds that DOE has abandoned the Nuclear Waste
Policy Act’s requirement that geologic isolation must be the primary form of
containment. We know, as you do, that DOE retroactively changed its site
suitability rules when it learned that the mountain’s natural site features
could not safely contain the waste. At the very least, the D.C. Court of
Appeals should be allowed to rule on the merits of that action before any
recommendation is made.